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Extended Producer Responsibility (EPR) for Packaging: A Guide

What is Extended Producer Responsibility (EPR) for packaging? Registration, packaging licensing, eco-modulated fees, EPR compliance across the EU and how EPR relates to the PPWR and the Digital Product Passport.

Author: myDPP Team

Extended Producer Responsibility (EPR) for Packaging: A Guide

Key Takeaways

Extended Producer Responsibility (EPR) makes producers, importers and retailers financially and organisationally responsible for the full life cycle of their packaging - in particular for its collection, sorting and recycling after use. Companies that place packaged goods on a market must register with the national packaging register, license their packaging through an authorised scheme and report the quantities they place on the market. Across the EU, EPR for packaging is being harmonised by the PPWR (Regulation (EU) 2025/40) and becomes mandatory from 2026. This article explains how EPR works, what obligations companies face, and why the product data it requires is the same data needed for the Digital Product Passport (DPP).

If you would first like to familiarise yourself with the Digital Product Passport, we recommend the introductory article Digital Product Passport in 15 minutes: what DPP is and why the EU introduces it.

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility is an environmental policy principle that extends a producer’s responsibility for a product to the post-consumer stage of its life cycle. Instead of municipalities - and therefore the general public - bearing the cost of disposal and recycling, the cost falls on whoever places the product or packaging on the market. The goal is to give producers a financial incentive to design less packaging, and packaging that is more recyclable and resource-efficient.

For packaging, EPR means three concrete things:

  • Registration: anyone placing packaged goods on the market must register before the first placement.
  • Licensing (scheme participation): packaging that ends up with private end consumers must be licensed through an authorised producer responsibility organisation (PRO). The licence fees fund collection and recovery.
  • Reporting: the packaging quantities placed on the market must be reported by material and weight - to the register and to the scheme.

How EPR works in practice

Compliance typically runs through two steps that are often confused but are both mandatory.

Step 1: Registration in the national packaging register

Every EU member state operates (or is establishing) a public packaging register. Registration is usually free of charge and must be completed before the first placement of packaging on that market. After registering, the company receives a registration number that must also be shown to the scheme and to online marketplaces. In Germany, for example, the register is called LUCID, operated by the Central Agency Packaging Register (ZSVR); since 1 July 2022 marketplaces may only list sellers who are registered.

Step 2: Licensing through a producer responsibility organisation

The actual packaging licensing takes place through an authorised scheme (a producer responsibility organisation, or “dual system” in Germany - for example Der Gruene Punkt, Interseroh, Zentek). The company reports the expected packaging quantities per material (paper, board and cardboard, plastic, glass, tinplate, aluminium, beverage cartons, other composites) and pays a licence fee. The scheme uses these fees to organise kerbside collection and recycling.

The quantities reported to the scheme and to the register must match (data reconciliation). Above certain thresholds an additional verified declaration of completeness may be required.

Until now, EU member states have implemented packaging EPR very differently - each country with its own register, its own schemes and its own reporting duties. A company selling cross-border currently has to register and license separately in every target market (for example LUCID in Germany, the CITEO system in France).

The PPWR (Regulation (EU) 2025/40) harmonises EPR requirements for packaging across Europe. It requires all member states to run packaging EPR schemes and introduces an eco-modulated fee structure: licence fees are to be based on the recyclability of the packaging. Highly recyclable packaging becomes cheaper, poorly recyclable packaging more expensive. This makes packaging data quality - material composition, weight, recyclability grade - directly relevant to the fee you pay.

For more on the packaging regulation itself, see PPWR Regulation: The New EU Packaging Regulation Explained.

Why EPR and the Digital Product Passport belong together

At first glance, EPR reporting and the Digital Product Passport are two separate obligations. In practice they rely on the same product data:

  • Material composition per packaging component
  • Weight per material
  • Recyclability and recycled content share
  • Mapping to the product and the sales unit

This is exactly the data required by EPR reporting, by the eco-modulated PPWR fee and - for products in scope of labelling - by the Digital Product Passport. Structure this data cleanly and per product once, and you can reuse it for all three purposes instead of maintaining isolated lists. myDPP models this data on a product-centric basis and serves it through the GS1 Digital Link - the same QR code that leads to the product passport can carry the packaging data.

EPR timeline: what applies from when?

  • Since 2019: national packaging EPR laws in force in leading markets (for example Germany’s Packaging Act, VerpackG).
  • Since 1 July 2022: extension to all producers in Germany; marketplaces and fulfilment providers must verify their sellers’ registration.
  • 11 February 2025: PPWR entered into force.
  • 12 August 2026: most PPWR obligations apply, including the framework for harmonised EPR schemes.
  • From 2028: eco-modulation of EPR fees based on recyclability is phased in (specified via delegated acts).

What should companies do now?

1. Map your packaging portfolio

Build a complete list of all packaging - sales, grouped and transport packaging - with material, weight and mapping to the product.

2. Check your registrations

Make sure all target markets are covered: the national register in each EU country where you place packaging. The registration number belongs in your master data.

3. Build the data foundation

Capture material composition, weights and recyclability in a structured, product-linked way - not in separate spreadsheets per authority.

4. Prepare for eco-modulation

Assess the recyclability of your packaging now, because from 2028 it will directly affect your licence fees.

5. Consolidate EPR, PPWR and DPP data

Use a single data source for EPR reporting, PPWR compliance and the Digital Product Passport, so packaging data is maintained only once.

Frequently asked questions (FAQ)

What is Extended Producer Responsibility in simple terms?

EPR means producers and importers bear the cost of collecting and recycling their packaging, rather than municipalities. Whoever places packaging on the market must register, license it and report the quantities.

What is the difference between registration and packaging licensing?

Registration is the (usually free) entry in the packaging register and a precondition for placing packaging on the market. Licensing is the paid participation in a scheme that funds collection and recovery. Both are mandatory.

Does EPR apply to small businesses and online sellers?

Yes. In most EU schemes there is no minimum threshold. Small quantities and pure online sellers are subject to registration and licensing as well.

What does EPR have to do with the Digital Product Passport?

EPR reporting, the eco-modulated PPWR fee and the Digital Product Passport all rely on the same packaging data (material, weight, recyclability). A shared data foundation avoids duplicate data entry.

What does the PPWR change about EPR?

The PPWR harmonises packaging EPR across the EU and introduces eco-modulated fees: charges will be based on the recyclability of the packaging.

Further reading

Sources

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